Maywald v. Commissioner of Social Security

CourtDistrict Court, W.D. Kentucky
DecidedMay 21, 2024
Docket5:23-cv-00089
StatusUnknown

This text of Maywald v. Commissioner of Social Security (Maywald v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, W.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Maywald v. Commissioner of Social Security, (W.D. Ky. 2024).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY AT PADUCAH CIVIL ACTION NO. 5:23-CV-89-CRS-LLK

RICHARD M. PLAINTIFF

v.

MARTIN O’MALLEY, Commissioner of the Social Security Administration1 DEFENDANT

MEMORANDUM OPINION & ORDER The Commissioner of the Social Security Administration denied Richard M.’s (“Claimant’s”) claims for disability insurance benefits under Title II of the Social Security Act. Claimant seeks judicial review of that decision pursuant to 42 U.S.C. § 405(g). This matter was referred to the United States Magistrate Judge for preparation of a report and recommendation. On December 18, 2023, the magistrate judge recommended that the Commissioner’s decision be affirmed. Report, DN 18. On January 2, 2024, Claimant filed a timely Objection to the Report. DN 19. Thus, this matter is now before the court for consideration of Claimant’s Objection. I. Background

On December 2, 2020, Claimant filed his DIB application alleging disability due to asthma, bladder cancer, degenerative disc disease, and right knee disorder. His claim was denied initially and on reconsideration. Claimant requested a hearing, and his request was granted. A telephonic hearing was held January 27, 2022. An impartial vocational expert testified at the hearing. On March 16, 2022, the ALJ issued a written decision. After evaluating the evidence under the required five-step process, the ALJ concluded that Claimant was not disabled within the meaning of the Social Security Act. Claimant requested review by the Appeals Council.

1 Martin O’Malley became the Commissioner of the Social Security Administration on December 20, 2023. Pursuant to FED. R. CIV. P. 25(d), he is substituted for former Acting Commissioner Kilolo Kijakazi. On February 2, 2023, his request was denied. As a result, the ALJ’s decision became final and subject to judicial review. 42 U.S.C. §§ 405(g) and (h); 20 C.F.R. § 422.210(a).

II. Standard of Review

The court conducts a de novo review of the portions of the magistrate judge’s Report to which Claimant has filed timely and specific written objections. FED. R. CIV. P. 72(b); 28 U.S.C. § 636(b)(1). To be specific, an objection must “pinpoint those portions of the” magistrate judge’s “report that the district court must specifically consider.” Mira v. Marshall, 806 F.2d 636, 637 (6th Cir. 1986). After considering all specific objections, the court may accept, reject, or modify, in whole or in part, the findings and recommendations made by the magistrate judge. 28 U.S.C. § 636(b)(1)(C). In reviewing findings by an ALJ, the court must determine whether those findings are supported by substantial evidence and made pursuant to proper legal standards. Rogers v. Comm’r of Soc. Sec., 486 F.3d 234, 241 (6th Cir. 2007); 42 U.S.C. § 405(h). If the ALJ commits an error of law, the court must reverse and remand, even when the decision is otherwise supported by substantial evidence and the outcome on remand is unlikely to be different. Kalmbach v. Comm’r of Soc. Sec., 409 F. App’x 852, 859 (6th Cir. 2011).

III. Analysis

Often, a claimant is disabled not because of his “underlying condition,” but because of “the symptoms associated with” the condition. Rogers, 486 F.3d at 247. Thus, one of the ALJ’s most important tasks is to evaluate a claimant’s symptoms. SSR 16-3p and 20 C.F.R. § 404.1529(c) govern symptom evaluation. There are two steps to symptom evaluation, the first of which informs the second. First, the ALJ must determine whether the claimant has a medically determinable impairment that could be reasonably expected to produce the alleged symptoms. 20 C.F.R. § 404.1529(c)(1). Second, where such a medically determinable impairment is present, the ALJ must evaluate the persistence, intensity, and limiting effects of the alleged symptoms. Id. at (c)(2)–(3). As to the second inquiry, the ALJ must consider two types of evidence: (1) the objective medical evidence of record, id. at (c)(2); and (2) other evidence, id. at (c)(3). There are seven buckets of other evidence:

1. Your daily activities; 2. The location, duration, frequency, and intensity of your pain or other symptoms; 3. Precipitating and aggravating factors; 4. The type, dosage, effectiveness, and side effects of any medication you take or have taken to alleviate your pain or other symptoms; 5. Treatment, other than medication, you receive or have received for relief of pain or other symptoms; 6. Any measures you use or have used to relieve your pain or other symptoms (e.g., lying flat on his or her back, standing for 15 to 20 minutes every hour, sleeping on a board, etc.); and 7. Other factors concerning your functional limitations and restrictions due to pain or other symptoms.

Id. at (c)(3)(i)–(vii); SSR 16-3p, 2017 WL 5180304, at *7. An ALJ need not consider all seven buckets of other evidence in every case, but she is required to “discuss the factors pertinent to the evidence of record.” Id. Other evidence must be considered because “symptoms sometimes suggest a greater severity of impairment than can be shown by objective medical evidence alone”. 20 C.F.R. § 404.1529(c)(2); SSR 16-3p, 2017 WL 5180304, at *5. Thus, an ALJ may not reject a claimant’s account of his symptoms based on objective medical evidence alone. Id. at *5; 20 C.F.R. § 404.1529(c)(2)–(3); Rogers, 486 F.3d at 248. Moreover, the ALJ’s decision must “contain specific reasons for the weight given to the individual’s symptoms, be consistent with and supported by the evidence, and be clearly articulated so the individual and any subsequent reviewer can assess how the adjudicator evaluated the individual’s symptoms.” SSR 16-3p, 2017 WL 5180304, at *10. Claimant contends the ALJ did not comply with SSR 16-3p and § 404.1529(c) because she did not consider other evidence when evaluating the intensity, persistence, and limiting effects of his symptoms. Fact & Law Summ., DN 13 at PageID# 1144. Instead, Claimant submits the ALJ considered only objective medical evidence (to the exclusion of all other evidence) to conclude that his alleged symptoms were inconsistent with the evidence of record. Id.

Upon review, the magistrate judge found no error in the ALJ’s analysis. He was unpersuaded by Claimant’s argument for two reasons: (1) SSR 16-3p and § 404.1529(c) require an ALJ to address only those “factors pertinent to the evidence of record;” and (2) an ALJ need not discuss every piece of evidence. Report, DN 18 at PageID# 1177 (quoting SSR 16-3p, 2017 WL 5180304, at *7).2 Thereafter, the magistrate judge concluded the ALJ’s decision was supported by substantial evidence and recommended the Court affirm. Id. at PageID# 1179.

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Related

Keith A. Mira v. Ronald C. Marshall
806 F.2d 636 (Sixth Circuit, 1986)
Debra Rogers v. Commissioner of Social Security
486 F.3d 234 (Sixth Circuit, 2007)
Terri Kalmbach v. Commissioner of Social Security
409 F. App'x 852 (Sixth Circuit, 2011)

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Bluebook (online)
Maywald v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/maywald-v-commissioner-of-social-security-kywd-2024.